Insights
2020 Year-End Sanctions and Export Controls Update
…marking a reversal from a prior decision in January 2020. Other European allies, however, have resisted an outright ban, with Germany signaling in December 2020 that it could allow Huawei’s…
Insights
China’s New Draft Export Control Law and Its Implications for International Trade
…rules and multilateral trading regime” and “object to unilateralism and trade protectionism.”[31] This announcement has been seen as a reaction to BIS’s inclusion of Huawei Technologies Co., Ltd. and its…
Insights
Regulatory Outlook for International Trade Following the 2024 Election
…a Huawei-specific foreign direct product rule intended to impede Huawei’s ability to procure certain items; and the removal of Hong Kong as a separate destination under the Export Administration Regulations…
Insights
BIS Initiates Rescission of AI Diffusion Framework; Issues Strong AI and Advanced IC Guidance and Warnings, with More to Come
…its guidance primarily on China and specifically calls out specific Huawei-made chips, namely the Huawei Ascend 910B, Huawei Ascend 910C, and Huawei Ascend 910D. BIS explains that its reference to…
Insights
United States Responds to the Crisis in Ukraine with Additional Sanctions and Export Controls
…Huawei affiliates designated on BIS’s Entity List, BIS created a new FDP rule to reach semiconductors, computers, and telecommunication items that were directly produced using U.S.-origin software, technology, plants, or…
Insights
2023 Year-End Sanctions and Export Controls Update
2023 was another extraordinarily active year in the world of trade controls, including sweeping new trade restrictions on Russia and China, aggressive enforcement of sanctions and export controls, and extensive…
Insights
Trump Administration Restricts Investments in Companies Linked to Chinese Military
…User Rule, the new Huawei-specific Direct Product Rule, and the recent spate of Entity List designations, as well as the U.S. Government’s procurement ban on certain technologies from several Chinese…
Insights
BIS Update Conference Takeaways: Expect “Dramatic Increase” in Export Controls Enforcement Against U.S. Adversaries
…a record-setting fine for alleged violations of the Huawei foreign direct product rule—Lutnick called for a concerted effort to fight against the possibility of what he described as “a controlled…
Insights
United States Creates New Export Controls on China for Semi-Conductor Manufacturing Technology, Advanced Semiconductors, and Supercomputers in New Phase of Strategic Tech Competition
…items to Huawei, BIS modified the national security-related control known as the Foreign Direct Product Rule to enable it to target a broader range of exports to specific companies that…
Insights
2021 Year-End Sanctions and Export Controls Update
Click for PDF The Biden administration made its mark on U.S. sanctions and export controls in 2021—reviewing, revising, maintaining, augmenting, and in some cases revoking various trade restrictive measures created…
Insights
2022 Year-End Sanctions and Export Controls Update
Policymakers in Washington, London, and other allied capitals during 2022 pushed the outer limits of economic statecraft to tackle challenges ranging from Russia’s full-scale invasion of Ukraine to China’s growing…
Insights
BIS Final Rule on Voluntary Self-Disclosure Process and Penalty Guidelines Highlights Significant Export Control Violations and Higher Penalties
…million civil penalty against affiliates of a technology company that allegedly sold hard disk drives to Huawei Technologies Co. Ltd. BIS is not alone in this prioritization, with CFIUS announcing…